Position papers

VdTÜV and DEKRA welcome the EU Commission’s proposal for a Regulation on type-approval requirements for motor vehicles and their trailers (COM/2018/286 final) dated 17 May 2018. The aim of the reform is to increase road safety and reduce the number of fatalities and severe injuries caused by accidents. The draft Regulation proposes far-reaching improvements in the field of active and passive safety. For example, new vehicles are to be equipped with automated braking and lane-keeping systems. New crash testing requirements are also planned.

Modern vehicles are no longer just hardware, but rather components of a digitally interconnected and integrated mobility ecosystem. The path to highly automated and connected driving goes hand in hand with a significant increase in complex and interdependent systems both inside and outside the vehicle. In future, it will be possible to make remote changes to a vehicle’s functionality from a cloud using radio technology.

DEKRA and the TÜV-Association (VdTÜV) are calling upon decision-makers to ensure a smooth transition and legal clarity for the type-approval of motor vehicles and certificates in rail transport in the UK and EU27 after Brexit.

In the “goods package” presented on 19.12.2017, the EU Commission is seeking to make adjustments in both areas in order to improve the functioning of the Single Market. With regard to market surveillance and also in the area of mutual recognition, the EU Commission has identified “structural weaknesses”, which it wishes to counteract by means of two Regulations. However, VdTÜV considers that the measures proposed in these Regulations are not suitable in order to adequately meet today’s challenges, eliminate the weaknesses and ensure the most com-prehensive compliance possible for the traded products. Therefore, VdTÜV sees a considerable need for correction as regards the legislation proposals, and wishes to comment as follows.

As part of the 2017 cybersecurity strategy, the European Commission (EC) published a regulation proposal for the “EU Cybersecurity Agency” and the “Cybersecurity Act” in September 2017. VdTÜV welcomes the objective the EC is pursuing with this legislative initiative: Strengthening trust in the security of products and ensuring a higher level of cybersecurity through a consistent framework for the certification of IoT products.

Tyres are the only point of contact between a vehicle and the road. Correct tyre maintenance and care are crucial for road safety – not only in winter times. VdTÜV e.V. recommends an extensive revision of the existing Tyre Labelling Regulation to increase the economic and environmental efficiency, as well as the safety of road transport by promoting fuel-efficient and safe tyres with low external rolling noise.

Modern cars with their large number of electronic control units are, according to the public opinion, susceptible to hacker attacks. Thus, IT security is becoming more and more important in the industry. VdTÜV emphasises three aspects that must be guaranteed: the operational safety of the vehicle, IT security and data protection as well as the privacy of drivers.

Why “legal harmonisation” and “mutual recognition” cannot be the best solutions for the removal of trade barriers between the EU and other states in the short or medium term. VdTÜV proposes a different, more pragmatic approach: Bilateral or Multilateral Conformity Assessments - they would ease trading significantly within the framework of trade agreements.

In order to improve road safety and environmental protection in Europe, procedures for placing vehicles on the market must be effective, transparent and clearly defined, as well as uniform in application.

The connecting of devices and machines on the internet to complex systems leads to extended functionalities which can no longer be solely located within the individual product itself, but are instead located within the back end system and/or product network.

National fee structures and a modified contractual relationship are not subject to the independence of the technical services. There is no causal link between the software manipulation of individual vehicle manufacturers and the objectivity of the technical services.